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Complete Story
09/18/2025
OSMA Comments on CMS’s Proposed 2026 Medicare Fee Schedule
Advocating for Fair Payment & Reduced Administrative Burden
The Ohio State Medical Association (OSMA) has submitted formal comments to the Centers for Medicare & Medicaid Services (CMS) in response to the proposed 2026 Medicare Physician Fee Schedule (PFS). This annual rule plays a key role in determining how physicians are reimbursed under Medicare and outlines regulatory requirements that directly affect the operations of physician practices.
While the proposed rule includes a temporary 2.5% increase to the Medicare conversion factor, OSMA raised strong concerns about several provisions that could have lasting impacts on physician practices across Ohio—particularly those that are small, rural, or independently operated.
One of OSMA’s primary objections is the proposed “efficiency adjustment,” which would reduce work relative value units (RVUs) and intra-service times by 2.5% across more than 7,000 procedure codes. OSMA opposed this across-the-board cut, emphasizing a lack of clinical justification. In fact, recent data suggest that procedure times are increasing—not decreasing. This adjustment would arbitrarily devalue physician work and add pressure to existing compensation models.
In its comments, OSMA also highlighted the insufficiency of the proposed payment update. The 2.5% increase to the Medicare conversion factor is not linked to inflation and does little to address the long-term decline in payment adequacy. Since 2001, Medicare physician payments have dropped by more than 30% when adjusted for inflation, while practice operating costs have continued to rise.
The proposed rule also includes a reduction in indirect practice expense (PE) payments for services delivered in facility-based settings such as hospital outpatient departments (HOPDs) and ambulatory surgical centers (ASCs). OSMA warned that these cuts would disproportionately harm independent physicians, limit patient access to care, and accelerate consolidation into large health systems—reducing competition and patient choice.
Finally, OSMA flagged the ongoing administrative burden associated with the Merit-based Incentive Payment System (MIPS) and the MIPS Value Pathways (MVPs). While the rule offers some technical refinements, the overall structure remains overly complex and resource-intensive, particularly for smaller and multispecialty practices. OSMA emphasized that the burden of reporting under these programs continues to divert time and resources away from patient care.
Ultimately, OSMA urged CMS to withdraw the proposed efficiency adjustment, adopt a permanent, inflation-based payment update aligned with the Medicare Economic Index (MEI), reconsider the proposed practice expense cuts in facility settings, and simplify MIPS and MVP requirements to better accommodate diverse practice models.
OSMA remains committed to fighting for fair payment, lower administrative burden, and the long-term sustainability of physician-led care in Ohio. As Medicare policies continue to change, we will keep advocating at the federal level to protect your practice and your patients.
While the proposed rule includes a temporary 2.5% increase to the Medicare conversion factor, OSMA raised strong concerns about several provisions that could have lasting impacts on physician practices across Ohio—particularly those that are small, rural, or independently operated.
One of OSMA’s primary objections is the proposed “efficiency adjustment,” which would reduce work relative value units (RVUs) and intra-service times by 2.5% across more than 7,000 procedure codes. OSMA opposed this across-the-board cut, emphasizing a lack of clinical justification. In fact, recent data suggest that procedure times are increasing—not decreasing. This adjustment would arbitrarily devalue physician work and add pressure to existing compensation models.
In its comments, OSMA also highlighted the insufficiency of the proposed payment update. The 2.5% increase to the Medicare conversion factor is not linked to inflation and does little to address the long-term decline in payment adequacy. Since 2001, Medicare physician payments have dropped by more than 30% when adjusted for inflation, while practice operating costs have continued to rise.
The proposed rule also includes a reduction in indirect practice expense (PE) payments for services delivered in facility-based settings such as hospital outpatient departments (HOPDs) and ambulatory surgical centers (ASCs). OSMA warned that these cuts would disproportionately harm independent physicians, limit patient access to care, and accelerate consolidation into large health systems—reducing competition and patient choice.
Finally, OSMA flagged the ongoing administrative burden associated with the Merit-based Incentive Payment System (MIPS) and the MIPS Value Pathways (MVPs). While the rule offers some technical refinements, the overall structure remains overly complex and resource-intensive, particularly for smaller and multispecialty practices. OSMA emphasized that the burden of reporting under these programs continues to divert time and resources away from patient care.
Ultimately, OSMA urged CMS to withdraw the proposed efficiency adjustment, adopt a permanent, inflation-based payment update aligned with the Medicare Economic Index (MEI), reconsider the proposed practice expense cuts in facility settings, and simplify MIPS and MVP requirements to better accommodate diverse practice models.
OSMA remains committed to fighting for fair payment, lower administrative burden, and the long-term sustainability of physician-led care in Ohio. As Medicare policies continue to change, we will keep advocating at the federal level to protect your practice and your patients.
Please review the full comment letter linked below, along with the official rule and CMS materials, and do not hesitate to email Sean McCullough with any questions or concerns.